Privacy Statement

Introduction

Embold Health Inc., (“Embold Health” or “We”) respect your privacy and are committed to protecting it. 

This Privacy Statement describes the types of information we may collect from you or that you may provide when you useemboldhealth.com including Embold Health Provider Guide or visit another website that is operated by Embold Health that displays a link to this Privacy Statement (collectively, the “Website”), and our practices for collecting, using, maintaining, protecting and disclosing that information.   

This Privacy Statement describes the types of information we collect from you or that you provide when you visit or communicate with us through Embold Health’s Website. The Privacy Statement does not apply to information collected by Embold Health offline or through any other means, including on any other website we operate that does not link to this Privacy Statement or any outside entity that may link to or be accessible from or on the Website.

Please read this statement carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our practices, you may choose not to use our Website. By accessing or using the Website, you agree to this Privacy Statement, where permitted by law. You are also subject to the Embold Health Terms of Use available at https://emboldhealth.com/terms-of-use relating to the Website, and this Privacy Statement is part of, and incorporated into, those Terms of Use.

This Privacy Statement may change from time to time (see Changes to our Privacy Statement). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, where permitted by law, so please check the Privacy Statement periodically for updates.

Information Subject to HIPAA

Embold Health is not a “covered entity” as that term is defined in the Health Insurance Portability and Accountability Act (“HIPAA”). To the extent that Embold Health receives “protected health information” as defined by HIPAA, it does so as permitted by HIPAA, for example, pursuant to a Business Associate Agreement with the covered entity. To the extent that you wish to exercise any rights under HIPAA, you should review the Notice of Privacy Practices of the relevant covered entity and/or contact such entity.

Information We Collect About You

We obtain information about you and your use of our Website when you visit our Website or sign up to receive communications from us. The information we collect can include Personal Information or non-Personal Information. “Personal Information” is any information that may identify, relate to, or be capable of being reasonably linked, directly or indirectly, with a particular identified or identifiable person or household. The Personal Information we may collect includes information such as your name, email address, telephone number, , and other information identified in this Privacy Statement or that you provide to us. Non-Personal Information is any information that is not Personal Information.

We collect information from you and any devices (including mobile devices) both when you provide it voluntarily and also automatically when you use the Website. In addition, we also collect Personal Information about you from third parties in connection with the Services, including from our service providers, business partners, or other third parties.

We may collect the following information from users of our Website:

• Account Information. We collect Personal Information, when you register or access to the Provider Guide, which may include your name, address, your subscriber or member ID or other information 
• Communication Information. We may collect Personal Information, such as contact information, or other information you provide, when you communicate with us through our Website, our support channels, and through email or other online services. Additionally, we collect your telephone number and your email address when you opt to use our SMS and Email Services, respectively;
• Search Information. We collect information about your search activities on the Embold Health product site available to you, including name, type, or geographic information of searched healthcare professionals; 
• Location Information. We may collect general location information or your geolocation if you use features on our Website that provide location-based services; and
• Usage Information. Information about your Internet connection, the equipment you use to access our Website, and usage details. For more information see the “Tracking Technologies” section below.

We collect this information when you fill in forms on our Website, including when you create an account, complete a survey for research purposes, or request further services, such as to view healthcare provider information, or otherwise communicate with us. We also may ask you for information when you report a problem with our Website.

Information We Collect Automatically

As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including your Internet protocol address, browser type, domain names, access times, and operating system, and details of your visits to our Website, including traffic data, location data, logs and other communication data, and the resources that you access and use on the Website. We also use these technologies to collect information about how you use our Website.

We collect this information in order to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Website; or
• Recognize you when you return to our Website.

Tracking Technologies

The technologies we use for this automatic data collection include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You must accept cookies to access Embold Health as a registered user.
• Web Beacons. Pages of the Website and our e-mails contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit Embold Health, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Web Analytics. We use analytics software to track aggregate and anonymous user behavior on our Website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Website and its content to you.
• To provide you with information, products or services that you request from us, including information about providers or facilities.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

How We Share Your Information

Embold Health will only disclose aggregated data about our users, and data that does not identify any individual, with those who have a legitimate need for it. Whenever we permit a third party to access aggregated data, we will make sure the aggregated data are used in a manner consistent with this notice (and any applicable internal data handling guidelines consistent with the sensitive and classification of the data). 

We may share Personal Information with third parties under the following circumstances:

• To our Service Providers. We use service providers to operate our software and infrastructure, in particular providers which host, store, manage, and maintain our Website, its content and the data we process. This includes hosting providers, communications service providers, and marketing service providers. We may share Personal Information with these service providers to enable them to provide services to us;
• To comply with legal obligations. We may share Personal Information to comply with our legal obligations, regulations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena, government audit or search warrant or in response to lawful requests by public authorities (such as national security or law enforcement. This Personal Information may be shared with counter-parties to contracts, judicial and governmental bodies
• To receive professional advice. We may share Personal Information to seek legal advice from external lawyers and advice from other professional advisers such as accountants, management consultants, etc.;
• In the course of litigation. We may disclose Personal Information if it is necessary to establish, exercise or defend against potential, threatened or actual litigation (such as adverse parties in litigation);
• To protect you or ourselves. We will share Personal Information where necessary to protect rights, property, or safety of Embold Health, our customers, your vital interests, such as safety and security, or those of others;
• To a buyer, successor of our business, or our affiliates. In connection with the sale, assignment or other transfer of all or part of our business (such as a potential purchaser and its legal / professional advisers); or
• With your consent. We may also share Personal Information for other purposes with your consent.

Please note that where legal requirements limit the sharing of your data, Embold Health will respect such requirements.

Your Rights and Choices Regarding Your Information

You can review and change your Personal Information by sending us an e-mail to privacy@emboldhealth.com to request access to, correct, or delete any Personal Information that you have provided to us. In some cases, we may not accommodate a request to change, for example, information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Marketing Preferences. We support the right of visitors to choose. If we collect Personal Information that could be used to provide you with marketing information, you will be given the right to opt-out of receiving any promotional materials about Embold or its partners. If you do not opt-out at that time, but later decide that you do not wish to receive future communications of this nature, you can contact us as set forth under “Contact Information” below, indicating that you no longer want to receive information relating to the Website. Please allow sufficient time for your preferences to be processed. Even if you opt-out of receiving marketing messages, we may still contact you for transactional or administrative purposes like confirming or following up on a request or report of an event. If you later opt back into getting marketing communications from us, we will remove your information from our opt-out databases.

Cookies. As noted above in “Information We Collect Automatically,” you can choose whether to accept cookies by changing the settings on your browser or device. However, if you choose to disable cookies, your experience with our Website may be impaired and some features may not work as they were intended. Some web browsers include a “do not track” setting. These features are not yet uniform, however, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Privacy Statement.

Your California Privacy Rights

Residents of the state of California have the right to request information regarding other companies to whom we have disclosed certain categories of information during the preceding year for those companies’ direct marketing purposes. At this time, Embold Health does not disclose any information to companies for direct marketing purposes. If you are a California resident and would like to make such a request, please email privacy@emboldhealth.com or write to us at 1801 West End Avenue, Suite 800, Nashville, TN 37203.

The rights above are separate from rights that consumers may have under the California Consumer Privacy Act and other state data privacy laws.  Please note that, at this time, Embold does not qualify as a “business” as defined by the California Consumer Privacy Act and does not meet the applicability requirements set forth in other state data privacy laws, including in Virginia, Colorado, Utah, and Connecticut, and therefore, Embold is not currently subject to such laws.  Nonetheless, Embold respects your privacy rights, and you can find information about the choices you have regarding your Personal Information further above.

Our Practices Regarding Children’s Information

Our Website is intended for users age 18 and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 18, we will delete that information.

Intended for Users in the United States

Our Website is provided and operated from the United States and are intended only for users in the United States. By using the Website, you acknowledge and agree to the transfer of information to the United States and to the application of the laws of the United States.

Do Not Track

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Currently, Embold Health does not respond to Do Not Track browser settings or signals. In addition, we deploy cookies, web beacons, and other technologies on our Website. Those tools may be used by us, our customers, and third parties to collect information about you and your Internet activity, even if you have turned on the Do Not Track signal.

Data Security and Retention

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All Personal Information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the Internet is not completely secure. While data is encrypted during the transmission or use of our Website and although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Embold Health will retain your Personal Information in accordance with our document retention policies and for the length of time required by applicable law. 

External Links

This Privacy Statement does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications that are linked or made available on our Website (“Third Party Services”). We do not take responsibility for the content, actions, or privacy policies of those Third Party Services. We encourage you to carefully review the terms of use and privacy policies of any Third Party Services you access.

Changes to Our Privacy Statement

It is our policy to post any changes we make to our Privacy Statement on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website’s home page. The date the Privacy Statement was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Statement to check for any changes.

Contact Information

To ask questions or comment about this Privacy Statement and our privacy practices, contact us at privacy@emboldhealth.com

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